Great Lakes Binational Toxics Strategy

Stakeholder Forum - 1998

IMPLEMENTING THE BINATIONAL TOXICS STRATEGY
Octachlorostyrene Workgroup

Minutes of the Octachlorostyrene (OCS) Workgroup Meeting
April 27, 1999

Discussion Topics

Discussion in the Octachlorostyrene (OCS) workgroup focused on the following topics; several action items were also identified.

One issue was whether or not our workgroup is close to completing work on OCS. Some workgroup members indicated that they were eager to "declare victory" on this substance, since levels of OCS in the environment appear to be decreasing. They believe that we may have reached a point where actions to reduce current sources of OCS may not lead to any significant reduction in risk, since most of the OCS in the environment appears to have been generated in the past, by sources which no longer exist. Questions as to how we decide when we have reached "virtual elimination" of OCS were raised.

It was pointed out that we really need to go through the four-step process, carefully answer questions, and see where we end up. We do not just want to wrap this up quickly-we want to be thorough and deliberate, and be able to defend our findings.

It was pointed out that we should use the decision tree prepared by Council of Great Lakes Industries (CGLI) to help us determine whether potential sources are actual sources, and to help us prioritize actual sources, so that we can focus our efforts on taking actions that will have the most benefit. US EPA and Environment Canada (EC) agreed to review this decision tree and to comment on it within the next few weeks.

There was some discussion as to whether the OCS workgroup should be combined with the HCB/B(a)P workgroup and/or the dioxins/furans workgroup. However, it appears that, at least for the near term, they will remain as separate workgroups.

The issue of how the OCS report was generated, and how comments received were (and will be) handled was discussed. Some workgroup members expressed interest in making comments available to workgroup members only, until the group had met and discussed them. They wanted to put comments on a "protected" website for review and comment. However, others indicated that there should be wider access to these documents. EPA discussed logistical problems with sending documents to workgroup members via email, as opposed to posting them on the web. As it turns out, this issue was discussed in detail at the Integration Group meeting on Wednesday, April 28. (See the minutes from that meeting.) The process agreed to there will be followed by the OCS workgroup.

The OCS inventory performed for Ontario was discussed. The second draft of this inventory is now available. CGLI’s comments were helpful and are incorporated in this version. A question was posed as to why secondary smelting was listed in the inventory as a potential source of OCS. It was explained that it is listed because plastic is sometimes burned in these furnaces before stripping, and when high temperatures, chlorine and carbon are combined, it is possible that OCS formation could result. If data could be presented to show this doesn’t happen, secondary smelting could be removed as a potential source. It was suggested that industry be encouraged to test for OCS when they are testing for other compounds; however, we need to keep in mind that this testing can be very expensive. 

Action Items

• Decision tree - Frank Anscombe and Debbie Siebers (EPA) and Darryl Hogg (EC) are to review the virtual elimination decision tree and call CGLI in approximately three weeks. Later, the decision tree is to be shared with the workgroup, and should be used in revising the draft OCS report. It should be used to help in rating priorities of sources.
• IADN -- Frank Anscombe (EPA) and Darryl Hogg (EC) are to continue working toward addition of OCS monitoring to the International Atmospheric Deposition Network (IADN).
• Diesel Engines -- Marcia Nishioka (Battelle) is to investigate diesel engine emission testing, and provide further information on this potential source.
• Fish data: Debbie Siebers (EPA) is to revise the draft table of OCS levels in fish shared at the meeting, and send it out to the workgroup via email. Darryl Hogg (EC) is to share Ontario fish data when it becomes available (within a month or so).
• Chemist - An expert will review OCS formation chemistry and provide insight to assist in EPA report revision, within approximately one month.
• NYSDEC contact -- Marcia Nishioka (Battelle) will contact the New York State Department of Environmental Conservation (NYSDEC) to determine the rationale behind their drinking water standard (6E-6 ug/l).
• Analytic Methods -- Frank Anscombe (EPA) will check on the "state of the art" in OCS testing and let Rubber Manufacturer’s Association know what he learns.
• Testing - The Rubber Manufacturer’s Association plans to conduct additional analyses for HCB in May/June, repeating tests they conducted in 1994. Those tests showed HCB for one data point; they believe that was an erroneous result. They may conduct tests for OCS as well, but are unsure at this point. We need to provide them a method (see 7 above). They will check whether EPA could be involved/witness the testing.
• Seek more Environmentalist involvement-This issue was raised at the Integration Group meeting on April 28. EPA/EC are to follow-up with National Wildlife Federation and Great Lakes United.
• Conference call - A call to discuss comments and responses was tentatively scheduled for mid- to late June. EPA/EC are to contact the workgroup and establish a time.
• Report revision-Battelle and EPA are to continue working on comment responses and report revision.